<<

“The Freedom of Speech Vs the Right to Discriminate; American and French Policy on banning Muslim Religious Attire”

Cortni Holthaus

A New Middle East

Spring 2016

3/31/2016

From hijab bans to TSA patdowns, the American and French government have shown no tolerance whatsoever to the people in the Muslim community in the aftermath of terror events such as 9/11 and the 2015 Paris Attack. In my essay, I explain why the American and French government have responded to these events the way they did, how it negatively affects Muslim people, and how the problem should be solved instead. The first and fourteenth amendments of the U.S Constitution, according to the American Civil

Liberties Union, gives religious Muslim women the right to wear hijab, because there can be no state or federal law which prohibits this activity. However, there is a major caveat in this amendment;

Sometimes, in a building like a school or an airport, hijab is not allowed, along with headscarves. This is because these public buildings often have a rule of no head coverings, and wearing hijab can be perceived as a safety issue, as the garment is loose, and items could potentially be stored under it. In the

US' laws and French laws surrounding the right to religious attire, the laws are often contradicting, and can be interpreted many different ways by the governments and other national institutions. My goal is to explain why the U.S and French are inherently Islamophobic towards Muslim clothing, and explain what can be done in order to ameliorate this problem, taking in mind the recent terror attacks in Paris, and of past events such as 9/11. [1]

All things considered, the government's refusal to accommodate for religious attire is very intolerant of Muslims and would seem to support the stereotype that all Muslims who wear hijab are automatically involved in terrorism and are plotting massive murder sprees, or preparing for a suicide bombing.

Eight years ago, in 2008, Lisa Valentine was trying to attend a traffic hearing for her nephew, but was not permitted to enter the courtroom due to her headscarf. Valentine then tried to leave, when she was detained by security officers of the courtroom and brought before the Judge Keith Rollins, who sentenced her to ten days of incarceration for contempt of court. One question here is, how is it that

1. (ACLU, 2010) refusing to take off a headscarf is a contempt of court, when it is supposedly permitted under the first and fourteenth amendments? [2]

Going back to the American Civil Liberties Union article, “Discrimination Against Muslim

Women-Fact Sheet,” overall there is an astounding amount of places where a girl or woman can be denied the right to wear a hijab or headscarf. These include, but are not limited to, schools and universities, jails, courthouses, athletic events, certain occupations, and many public buildings and attractions like amusement parks and swimming pools. [1]

One extreme example of this discrimination in America's laws is when in 2011, there was a large brawl at the New York Rye Playland after a group of Muslim women, accompanied with Muslim men as well, refused to remove their headscarves before going on the rides at the park. This led to a large argument among the group of Muslims with local police officers which then spiraled into a large scale fight. According to Ayman Alrabah, she and her sister did not know of the rules prohibiting headscarves before getting to the ride, stating, “We requested a refund and all of a sudden an argument became a riot.”The amusement park's response to the treatment of the group was very apathetic with the park official Peter Tartaglia issuing the statement, “We respect the religious purpose of wearing it, but we have several rides that you cannot go on with any sort of headgear,” after discussing how the rules are for a safety purpose, as opposed to religious discrimination. [3]

1. (ACLU, 2010) 2. (Nasaw, 2008a) 3. (Duell, M. and Whitwell, L, 2011) In the case of safety purposes, it is understandable that the Rye Playland park had the right to

.refuse service to the group of Muslims and to not permit them onto the ride, but the reactions they received from the local law enforcement was too overpowered, and certainly not necessary to cause as big of a scene.

Referring to the treatment the cops gave the group, Ayman Albrah tells us,

Cops came. They were hitting my brother, my dad. My husband was on the floor and they were handcuffing him.Previously in the article, one Muslim claimed as well, It's clear, this all happened because we're Muslim. [3]

The statement of the police brutality occurring because the visitors were Muslim brings up the argument of whether or not law enforcement treats each citizen equally under the law, or is inherently racist and discriminatory.

In the Washington Post article, “Being a cop showed me just how racist and violent the police are. There's only one fix,” by former police officer Redditt Hudson, Hudson describes his induction as a police officer in St. Louis, Missouri and his experience with while on the job. One prime example Hudson provides is how other officers were involved in the website exclusively for St. Louis officers called Coptalk, where “Cops routinely called anyone of color a “thug,” whether they were the victim or just a bystander.” This of course falls under the spectrum of , which is just as damaging to a society as religious profiling is; They both prevent healthy relationships between people

3. (Duell, M. and Whitwell, L, 2011) internationally, and contribute to a massive amount of violence and harm to the victims involved. [4]

Hudson claims that;

The problem is that cops aren't held accountable for their actions, and they know it. These officers violate rights with impunity. They know there's a different criminal justice system for civilians and police.[4]

He also says that many of the trials for excessive force or breaking a suspect's rights are brought forth often by a police officer's close colleagues, who would give the trial a biased opinion, which would only favor the officer most certainly, preventing the suspect from receiving a fair trial. [4]

As stated before, police officers do not only profile people of color, but also of religion.

The Free Thought organization's article, “So It Begins: Cop Threatens To Arrest Muslim Woman

For Wearing A Hijab” by Claire Bernish, Bernish describes a shocking scene of Islamophobia post

Paris and Brussels attacks. A Muslim woman wearing hijab in a public library in Washington D.C was asked by a police officer to remove her hijab, and given an ultimatum to either leave immediately, or to be escorted out by the officer. Bernish explains how this Islamophobia will only make the West's experience with terrorist attacks much worse, claiming

4. (Hudson, R, 2014) Any group subjected to continuous discrimination and constant denigration will first experience fear, but eventually that fear begins to translate to resentment. When resentment builds to an ultimate level, it tends to translate to action-not in carrying out a terrorist attack, but in a more insidious way.[5]

Returning to the first article about Women's freedom to wear hijab, this denigration as described by Bernish is what causes many young women to join Daesh, because Daesh offers a way out for these women, and promises of better lifestyles if they simply join the group. [1] [5] The Business

Insider article tells us that the way out for these women is not only in becoming married to jihadi fighters in the article, “ISIS is luring Western women with troubling simplicity” by Danica Kirka.

Kirka first starts discussing to the audience that women joining ISIS should not be viewed as a joke, as ISIS is extremely radical, and some women join ISIS due to the persecution of their Muslim beliefs, along with wanting a sisterhood with other young women. Returning to the article, “Georgia judge jails Muslim woman for wearing headscarf to court,” perhaps this is what Kirka is describing in her argument; that Muslims faced with intense discrimination towards their beliefs and activities of their beliefs can become radicalized and join terrorist organizations. [2] [6]

The intense persecution that Kirka is describing can certainly cover Muslims being denied access to public places, and also includes brutality shown towards them and violent acts towards members of their community, like in the Rye Playland Park. [3]

1.(ACLU, 2010)

2. (Nasaw, D, 2008a) 3. (Duell, M. and Whitwell, L, 2011) 5. (Bernish, C, 2016) 6. (KIRKA, D. and Press, A, 2015) Another article from the American Civil Liberties Union titled Factsheet: The NYPD Muslim

Surveillance Program, brings up that since 2002 (post 9/11), The NYPD's Intelligence Division has been deliberately profiling members of the community in order to 'prevent' terrorism which involved the NYPD spying and watching neighborhoods with a large Muslim percentage and recording license plate numbers of people leaving mosques. [7] One separate but related article by The Guardian,

“Racial profiling by law enforcement is poisoning Muslim Americans' trust” would also agree with

Kirka's sentiment on religious profiling when the author of the article, Sahar Aziz states,

Millions of dollars are spent flying bureaucrats from various federal agencies to meet and greet Muslim leaders, most of whom are male, in an attempt to earn their trust. In those meetings, local and state law enforcement is invited to build long-term relationships with the Muslim communities in their jurisdictions. On the face of it, the meetings appear to be a good-faith effort to demystify Muslims and counter false stereotypes of Muslims as terrorists. In practice, the objectives are more duplicitous. [8]

The duplicitous objectives the federal agencies attempts to try and 'watch' these Muslim leaders conjure up terror schemes, and they try and become friendly with these people as nothing more than a ruse to make them comfortable enough to share their ideas. However, doing this damages the

Muslim community as a whole and prevents these people from using free speech as protected by the 1st

Amendment. Of course, making threats to anyone or any particular place is certainly a criminal act, regardless of race or religion, but Muslim people feel afraid to be engaged in any public events like protests or rallies, in case they are profiled by the government doing 'illegal' activities. [7] [8]

A few days before a lawsuit was brought to court which accused the NYPD of spying on

7. (ACLU, 2016) 8. (Aziz, S, 2012) Muslims, New York Post article, NYPD ready to settle case over spying on Muslims, Republican Peter

King agreed with the need for the Muslim Surveillance Program, stating, “Take a look at Paris. You can see why these programs are necessary.”[9]

This is an extremely illogical argument to make because the actions of a few Muslims (Daesh) should not condemn other completely innocent Muslims. The NPR confirmed that multiple suspects were detained in Paris suspected of being involved in the attack on November 13, 2015, and in a separate NPR article titled “Paris Attacks Live Updates: French Authorities Identify Key Players,” after the arrest of the 23 suspects and the placement of over 100 citizens on house arrest, the French police were able to decide that Abdelhamid Abaaoud and Salim Benghalem, both Belgian and French natives respectively. [10] [11] If these two men were of Western origin, this would mean that even though certainly Muslims from the Middle East join ISIS and other terrorist organizations, so do Western civilians. Ultimately, it could be said that the problem lies in the West as well as the East.

President Obama at the G-20 meeting said of the Paris attacks and the call to bar Syrian refugees from immigration,

The people who are fleeing Syria are the most harmed by terrorism; they are the most vulnerable as a consequence of civil war and strife, and We do not close our hearts to these victims of such violence and somehow start equating the issue of the refugees with the issue of terrorism.[11]

9. (Edelman, S. and Schram, J, 2015) 10.(Peralta, E, 2015) 11. (Peralta, E, 2015a) If the problem of terrorism is also caused by Western civilians, why then is there a need to attack only Muslim civilians, particularly ones who are wearing religious attire?

According to the HuffPost Religion article, “Is the NYPD Really Against Muslims”, the author

Daisy Khan explains that thankfully the spying on Muslim citizens from the NYPD is being re- mediated. Khan says that instead of judging all Muslims as extremists, it would be better for them to also be in the fight against extremism as well. She claims that, “Now, there are almost 1500 Muslims serving in NYPD with police officers patrolling the streets in all boroughs, 350 of them belong to a

NYPD Muslim officers Society formed in 2008, with their very own Muslim chaplain, Khalid Latif, who ministers to the need of NYPD's uniform and civilian members.” [12] This is great progress for the people of the Muslim community, but is still not enough.

The problem with Muslim members joining the police force is that they could be targeted in their own profession for their religious clothing if they are even allowed to wear such clothing on the job. If we return to the American Civil Liberties Union article, “Discrimination Against Muslim

Women-Fact Sheet,” we can refer to the fact that some careers will not allow for their employees to wear hijab or other religious clothing sometimes. [1]

In Allen West's article, “Watch: What this Muslim Police Chief just did goes against

EVERYTHING that is America!,” We can see that even with the new amount of Muslim citizens

12.(Khan, D, no date) 1 .(ACLU, 2010) becoming police officers, they are still highly scrutinized, for simply not being patriotic. Assistant chief of police in Miami, Anita Najiy, only refused to put her hand over her heart during the pledge of allegiance- an act which was condemned by Police President Javier Ortiz, who stated of the assistant chief's actions, “If you're not pledging allegiance to the , my question is what country are you pledging allegiance too? [13] The problem with Ortiz' statement is that it assumes all Americans who are faithful to the United States are all very patriotic, an assumption which is not true, and uses this to further discriminate against the Muslim community, and help people demonize more people wearing hijab, and to disrespect perfectly able Muslim police officers.

Muslim community members are not alone in refusing to say the pledge, in fact, it is well known that many non Muslims will also either stay seated during the pledge, or refuse to put their hand on their heart. In the article, “School Nurse Refuses To Treat Child As Punishment For Sitting Down

During Pledge of Allegiance by The Free Thought Project author Jay Syrmopoulos, a Middle School student at Wilson Middle School was at her school's nurse's office when the pledge was announced over the intercom. The girl refused to stand up when the nurse requested that all the students in the office stood. If we go into the pledge of Allegiance's lyrics, we can easily tell that the pledge is very inundated with religious overtones and overtly patriotic sentiment, and some people may feel offended by this, and some people may not wish to express any patriotism. Since religion is involved in the pledge, entirely Christian, it would seem to be protected under the Constitution for someone to not be required to say the pledge, even though it is mostly a custom currently. [1] [14] Continuing with the

1. (ACLU, 2010) 13. (123, V, 2015) 14. Syrmopoulos, J, 2015. Constitutional rights of American citizens, in the article, “Hijab for female police officers: Is it really needed?,” by TheJakartaPost journalist Adrianus Meliala, Meliala describes how the female National

Police officers in Indonesia can/should only wear hijab in certain situations.

When a female officer is assigned in Aceh province, where women must be covered under the local sharia bylaws', Meliala tells us that Aceh is the only province allowed to apply Islamic law following the 2005 international peace agreement between the government and the former Free Aceh

Movement (GAM). [15] He also claims that, “Members of the National Police should be treated equally. One way to do that is through the use of the uniforms that are neutral in terms explicit statements of association. The hijab may be seen as partiality toward certain groups by police.” [15]

Simply, it seems that Meliala is saying that because the police are constantly seen by citizens, they cannot risk looking as if they are affiliated with one certain group of people, because this could cause concern among the people regarding police favoritism.

If I were to compare Meliala's scenario to another example, people could just look at school uniforms. The idea behind school uniforms is usually so that no student gets bullied for their outfits, because they are all the same, but differentiated for each gender. The clothing students wear may have affiliations on it such as brand names or other words or pictures which may or may not resemble that particular student's ideologies and beliefs. [15]

15. (Post, T.J, 2016) Speaking of school, hijab is often banned in many public institutions of education. [1] In BBC's article, “Can schools ban the veil,” by education editor Branwen Jeffreys, Jeffreys writes about a court case where a young 13 year old girl, Shabina Begum, who was turned away from the school she was trying to attend because she was wearing a jilbab, a long dress like garment covering a person from head to toe, which was not allowed in the school's dress code. The case was brought up over the next two years in U.K courts, but ultimately the school was the successor in the end. Jeffreys describes the reason for Shabina's loss: [16]

In the end, the school won the argument that her right to show her religion had not been infringed, although the Law Lords were not unanimous in their decision. One of the arguments taken into account was the potential pressure on other girls to adopt similar clothes. But, 10 years on, it is hard to know how a similar case would be weighed up in the courts. The Shabina Begum ruling was decided on the detailed circumstances at that school at that time. [16]

After researching the official case, I found that in the official U.K Parliament document regarding the case, titled “Opinions Of The Lords Of Appeal For Judgement In The Cause R (on the application of Begum (by her litigation friend, Rahman)) (Respondent) v. Headteacher and Governers of Denbigh High School (Appellants) Appelate Commitee” under the agreed facts section, two of the most important opinions related to Meliala's article was,

The head teacher believes that school uniform plays an integral part in securing high and improving standards, serving the needs of a diverse community and avoiding manifest disparities of wealth and style. The school offered three uniform options. One of these was the

1. (ACLU, 2010) 16. (Jeffreys, B, 2016) shalwar kameeze: a combination of the kameeze, a sleeveless smock-like dress with a square neckline, revealing the wearer's collar and tie, with the shalwar, loose trousers, tapering at the ankles. A long-sleeved white shirt is worn beneath the kameeze and, save in hot weather, a uniform long-sleeved school jersey is worn on top. It has been worn by some Muslim, Hindu and Sikh female pupils, and The House of Lords tells us of this that;

The respondent issued her claim for judicial review on 13 February 2004. Since then, according to the appellants, a number of Muslim girls at the school have said that they do not wish to wear the jilbab and fear that they will be pressured into wearing it. A demonstration outside the school gates by an extreme Muslim group (unconnected with the respondent) in February 2004, protesting against the education of Muslim children in secular schools, caused a number of pupils to complain to staff of interference and harassment. Some pupils were resistant to wearing the jilbab as unnecessarily restrictive and associated with an extremist group. The head teacher and her assistant, and also some parents, were concerned that acceptance of the jilbab as a permissible variant of the school uniform would lead to undesirable differentiation between Muslim groups according to the strictness of their views. The head teacher in particular felt that adherence to the school uniform policy was necessary to promote inclusion and social cohesion, fearing that new variants would encourage the formation of groups or cliques indentified by their clothing. The school had in the past sufferred the ill-effects of groups of pupils defining themselves among racial lines, with consequent conflict between them. The school uniform had been designed to avoid the development of sub-groups identified by dress. [17]

These opinions have very many logical fallacies. First off the argument does well in stating that the school was worried that if a variant was allowed on the three accepted school uniforms, this would cause disparity of wealth and style among the students. However, upon seeing what the jilbab looked like compared to a shalwar kameeze, both looked relatively modest and neither seemed to reflect wealth.

The shalwar kameeze in fact looks bright and colorful and often has embroidered patterns on it and looks much like a tunic style top with trousers that look like very loose pajama bottoms, while on the other hand, the jilbab looks more like a long robe or dress, and also can come in many different

17. (HOUSE OF LORDS, no date) colors with designs like the shalwar kameeze. Even though the school clearly has a strict dress policy, they don't specify what specific color or how plain the outfits need to be; essentially the situation could end up with one student simply having a better color of the shalwar kameez compared to a different pupil. Many dress codes internationally fail to address many loopholes within their code, and many students will often tweak their uniforms to bring forth their individuality, to the dismay of the school.

Everyday Feminism's article, “4 Lies About School Dress Codes That Cover Up Their Oppressive

Effects,” article writer Ellen Kate explains why dress codes are problematic and don't really solve the problems they claim they do. Her biggest example was that dress codes do not make it so that all students are more equal to each other, because students can follow the dress code and still wear items which show wealth and status comparatively to other students in the school. Kate states of this,

So, far from putting all students on equal footing, dress codes disproportionately affect certain students more than others and the idea that a dress code will prevent students from noticing difference is laughable. Cell phones, sneakers, and jewelry all help point out those distinctions just fine- not to mention where kids live, what they bring for lunch, the car a parent drops them off in, the spending money they have, and a thousand other markers.[18]

Going off of Kate's quote, its easy to see why dress codes really aren't going to solve the problem of equality in schools; the dress code may only state that a student must wear sneakers for example. If one student wears an off brand pair of sneakers, while the other student wears Nike brand sneakers, chances are that the other student will be viewed more favorably by other students, because branding is a major influence in schools that affects students behavior. In the International Journal of

18. (Kate, E, 2014) Business and Management Volume 6 in June 2011, the volume discussed how branding works to attract consumers using the example of the water bottle industry in Southeast Nigeria. In Nigeria, because the water is not always of healthy drinking quality, in many areas plastic water bottles are a necessity for a community so that illness may be avoided. Given that some water companies may filter their water differently than others, surely certain brands of water will be better tasting and have a lower risk of being contaminated, which most likely will be more expensive. This will then show the difference between a rich person's choice of water and a poorer person's water bottle choice. [19]

According to the data collected by the journal, over half of the people surveyed firmly believe that their brand of water bottle is definitely better than other brands of water. This would imply that people really like to stick with what they know, and having a familiar trusted brand for them gives them a large sense of comfort. [20]

The Daily Mail article, “Mother knows best: Why we stick to the same brands our mums used to buy,” sticking to a brand is shown to be an ingrained idea in people's minds based upon familiarity during childhood. A report on British mothers even showed that they will typically only use a total of

18 products that they have faith in, and will also buy these certain brands of product, even if they happen to be more expensive. [21]

The Nielsen article, “Tried And True Or Adventurous: Do Consumers Stick To Their Favorite

Alcohol Brands,” also states that age is a very important factor, and that youth are more brand

19.(Ogbuji, C.N., Anyanwu, A.V. and Onah, J.O, 2011) 20. (Ogbuji, C.N., Anyanwu, A.V. and Onah, J.O, 2011) 21. (Reporter, D.M, 2011) “promiscuous” and often purchase many different types of brands instead of sticking to a select few.

The article tells us of this,

Almost one-quarter (23%) of wine drinkers aged 21-34 have purchased 10 or more wine brands in the past year versus less than 20% of all wine drinkers aged 21 and older. Almost 10% of spirit drinkers aged 21-34 have tried more than 10 brands in the past year, compared with only 5% of all spirit drinkers 21 and older. Similarly, younger beer drinkers are more apt to purchase a broader set of brands. The tendency for younger drinkers for trying a broader set of brands is likely a result of their more adventurous nature, as well as the likelihood that their “favorite” products may have not as yet been established. [22]

After researching the effect of age on consumerism in general, I found that the article, “The

Impact of Aging on Consumer Responses: What Do We Know?” tells us about how the population in the United States is steadily becoming more elderly, with 15% of the nation's population being over age

65. [23]

Given the fact that the United States is an aging population like many Eastern Asian nations today, Japan for example, the older generation may be influencing what the newer generation thinks about Muslims. The CNN article by Chuck Walton, “Will racism end when the old guys die off? Doubt it, Walton describes how the millennial generation of youth is just as racist as the previous generation was in their youth. Walton explains how in our current society, it is even easier for racism to exist through the use of social media and tells us,

We millennial are the “here today, gone tomorrow” type of activists. This is most disappointing because access of information is easier than ever before. You no longer have to be rich or 22 .(Tried and true or adventurous: Do consumers stick to their favorite alcohol brands?, 2015) 23. (Gregoire, Y, 2016) famous to have a voice. Just get a Twitter handle, post to your Instagram page or fire up your WordPress blog. So the question becomes, what happens next? We cannot simply stand by celebrating surface victories while the problems persist. Racism, as with all other prejudices, has to be attacked at the source. It will not become extinct with the passing of the older generations. A new racist is born every minute.[24]

If we think about that quote from Walton, we see that it means even the elderly have access to be racist in new ways that were not previously there, and young people also can access these platforms to discriminate based upon a person's race or ethnicity. Unfortunately, Walton also is stating that people in general can be racist, and it is not just based upon which generation they are from, but has multiple factors instead.

The Guardian's article, “Why are people racist? You asked Google-here's the answer, by Joseph

Harker, Harker explains how racism can occur because of negative stereotypes placed upon different races and it can occur through fear of the other “race”. Harker tells us why Muslims are so persecuted in the United States, stating that;

And it's there in the way Muslims are commonly perceived as a threat-be it from terrorism or grooming, despite the numbers committing these crimes being relatively tiny- because their religion is considered, by some, to be primitive. And although Islam is a religion rather than a race, these attacks are often racist in essence, because of the religion's strong association with people from a Middle Eastern or Asian background.[25]

This racism can easily be seen through images in media and other forms of art; Just from a simple Google image search of 'middle eastern person' will show photos of people wearing T Shirts stating that they are not terrorists while smiling for the camera, or of people with bombs strapped to their chest. It only became worse as the search was only narrowed to 'Muslim.' You can instantly see

24. (Walton, C, 2014) 25. (Harker, J, 2015) cartoons of women being oppressed in their hijabs, and of a strange sexualization of the veil and parodies of how the West views Islam and subsequently, the Muslim people of the world.

Using the book by Jasbir Puar, Terrorist Assemblages, Muslim people become like an other group in the United States, much like how gays and lesbians are often excluded socially because heterosexuality is deemed more appropriate for the status quo, and has not truly progressed to become more inclusive of gays and lesbians, and certainly not of Muslims. [26]

The article by The Washington Post, “Hating Muslims plays right into the Islamic State's hands, shows how we often 'other-ize' the Muslim community after a major attack like 9/11 or the Paris

Attacks in 2015. The assumption that people have is that based on the actions of a small percentage of people, the rest of the people must be condemned as well, and are labeled as if they are terrorists, even if they are completely innocent. Jeff Guo, the author of the article tells us that,

The moments after a terrorist attack are often filled with acts of reprisal. In the six months after the Charlie Hebdo attacks in January, anti-Muslim violence and Mosque vandalism more than quadrupled compared with the same period in 2014, according to the Collective Against Islamophobia in France, a watchdog group. Extremist groups feed off of alienation, some counterterrorism experts say, and Islamist militants deliberately aim to make Muslims in the West feel isolated and turn against their own communities. [27]

The biggest example of acts of reprisal towards Muslim people was after the 9/11 attacks. In the article by the Southern Poverty Law Center, “9/11 Anniversary Sparks Hate Crimes Against Muslims,”

SPLC discusses how during the tenth anniversary of the tragedy, outrage was still present in many citizens who took out their anger upon Muslim citizens through actions such as burning Korans, or

26. (Puar, J.K, 2007) 27. 27. (Guo, J, 2015) vandalizing Muslim mosques and houses in the area. SPLC states that immediately after 9/11, hate crimes towards Muslims rose to 1,600%. [28]

Much of the reprisal was also given to the unintended target- members of the Sikh community, because many Americans cannot distinguish the Sikh turban from that of authentic Muslim garb, like a keffiyeh. In the HuffPost religion article, “History of Hate: Crimes Against Sikhs Since 9/11, the author describes many incidents in which members of the Sikh community were attacked only months after

9/11. Of the over 300 incidents reported, many of them took place around a place of business, like a grocery store, or around a Sikh place of worship, called gurdwaras. For example, in 2003 in Tempe,

Arizona:

Sikhvir Singh, a 33-year-old convenience store owner, is stabbed to death by Bruce Phillip Reed. It is not labeled as a . Representatives of the Phoenix Sikh community issue a statement that says, in part, “Together we can help others to evolve past hate and fear by continuing to organize to reach out to others with increased understanding, respect, and support. May our collective prayer be that God preserve and protect the honor of all people, our nation, and our world.[29]

This shows us that many people have a distorted view on who the Sikhs are, because they are in no way related to the Muslim faith, and the outfits are only coincidentally 'terrorist looking' an idea which many Islamophobic people hold. Going back to images, one Google image search of Sikhs provides us with pictures of an Orientalist depiction of them, holding swords and wearing elaborate

28. (9/11 anniversary sparks hate crimes against Muslims, 2011)

29. (TheHuffingtonPost, 2012) turbans, many of them as older men, many with their hands in a prayer position.[30]

Other pictures show Sikh people are innocent and are not Muslims and do not deserve to be profiled and how they are constantly checked out by government officials or are condemned by people as terrorists. One prime example of this was of a selfie by Veerendeer Jubbal, who had posed in front of a mirror originally with just his turban and an Ipad in his bathroom, but was photoshopped to be wearing a suicide bomber style belt and holding the Holy Qur’an. This was in the wake of the Paris

Attacks, and the group Gamergate was to blame for framing this Sikh man. [31]

The Atlantic article, “The Trouble With Wearing Turbans in America,” explains how the Sikh community needs to be not associated with terrorism because of religious affiliation, showing us that many of the people portrayed as terrorists are those with darker skin, with different styles of clothing, that are mistakenly symbolized by Western culture to denote someone who is a 'terrorist.'

Author Emma Green states of this,

Many people would see honesty, compassion, generosity, and humility as good character traits in a person, so how then did something like a turban (or a hijab) become so synonymous with danger, or something to be taken as a threat? [32]

The Al-Jazeera article, “Satire as wearing hijab is labeled 'passive terrorism' discusses how the

US military defined hijab wearing as an action of passive terrorism because in the White Paper they

30. (Sim, D, 2015) 31. (Garg, B, 2015) 32. (Green, E, 2015) produced, they defined passive terrorism as “a phenomenon which is said to occur when “moderate segments of the population decline to speak against or actively resist terrorism.” Because of this broad statement, Muslim women who wear hijab are certainly terrorists, but so are many other people, who may or may not have any religious affiliation. [33]

The website Al-Islam's article, “Why Hijab,” states that the hijab is worn by women in the

Middle East to make the women less of an object and makes it so that others can view them for their personality and character, and not just their outward appearance. It is also very helpful for women who are mothers as the shawls and veils provide easy access for breastfeeding and allow for the mother's stomach to expand during pregnancy. [34]

The BBC article, “Hijab,” gives a brief description about the origin of hijab wearing and why it is so important to the Muslim faith. Going from BBC's description of hijab, “It is the principle of modesty and includes behaviour as well as dress for both males and females,” it would seem that the

Western interpretation of the hijab is very skewed and for many conjures up images of not only terrorism, but also of and of a severely oppressed people. The way that the article describes hijab would seem to tell us that wearing hijab is an outward expression of a Muslim's modesty and of good behaviour, rather than a simple concealment in which someone is oppressed. [35]

Women who wear hijab are called Muhaajaba, and women are not always required to wear hijab, but are expected to wear hijab in front of males they could marry, which excludes all family

33. (Network, A.J.M, no date) 34. (Why Hijab?, no date) 35. (BBC, 2009) members, and of other women or of children. A Quranic verse is the reason for why hijab was adopted for women because verse 24:31 states that; [35]

And say to the believing women that they should lower their gaze and guard their modesty; that they should display their beauty and ornaments except what (must ordinarily) appear thereof; that they should draw their veils over their bosoms and not display their beauty except to their husbands, [a list of relatives], [household servants], or small children who have no sense of the shame of sex; and that they should not strike their feet in order to draw attention to their hidden ornaments. And O ye Believers! Turn ye all together towards Allah, that ye may attain bliss.[36]

There are many different interpretations of this popular Quranic verse, and many scholars debate over whether or not a woman should have everything covered besides the eyes from head to toe

(niqab), or whether showing the face and the hands is acceptable in society. The verse is not entirely specific about how much coverage of the body a woman needs to maintain, except of at least covering the breast area and to be modest. One interpretation of modesty would to not appear as flashy or attention seeking in any way. For example, a Muslim woman wearing a full face of exaggerated makeup, wearing short skirts/dresses, and showing cleavage would not be very appropriate for the meaning of hijab, the principle of modesty, and it would therefore go against the tenet of the hijab. [35]

An article on The Daily Beast's website describes a few women's experiences wearing hijab, and how they have to endure the constant stereotyping of others who believe they are oppressed or powerless. Layla Shaikley, a member of the USA national fencing team, believes that her hijab truly sets her apart from Muslim women who choose not to wear the hijab, telling us that, “If she takes it off,

Shaikley says she would be seen as just someone ethnic, but by leaving it on, she is literally wearing

35. (BBC, 2009) 36. (Haleem, M.A.A. and M A S Abdel Haleem, 2008) her beliefs on her head.” Shaikley's statement is very understandable. For example, if we were to see in public a Chinese woman wearing 'American' styled clothing, nothing would be thought of it, but if that woman were to were Buddhist Nun garments or a qipao, she would be noticed, and many people would view this under an orientalist lens, viewing the qipao as what it must mean to be Chinese, and for the

Buddhist Nun garments to be similar to a hijab, and therefore a sign of oppression. [37]

Going back to the article, “Why Does the Hijab Get Such A Bad Rap?” again, The Daily Beast explains why Shaikley believes that the discrimination against hijab wearers occurs because, “Shaikley believes the discrimination stems from the fact that Muslim Americans are often underrepresented or misrepresented in the media. She states of this that, “It is easy to sensationalize Muslim Americans without a more accurate portrait of the leaders, artists, intellectuals, academics, and educators that the community offers to our country every day.” [37]

Shaikley's statement implies that most Americans don't understand the big picture of how

Muslim people have been beneficial to the American society as a whole, and instead focus far too much attention on negative stereotypes of the Muslim faith which end up harming relations between peoples in a community.

In the article, “Want to Help ISIS? Hate A Muslim,” by Leslie Marshall, Marshall explains that the persecution towards Muslims due to events carried out by a few Muslims and then extrapolate this to decide that all Muslim people are evil and that the religion itself promotes violent and harmful behavior, especially towards people of a different faith. Marshall shows us that not much is done to

37 . (Nadeau, B.L, 2014) prevent people from instantaneously judging Muslims when a terrorist attack has occurred, stating that:

“And while we sit back and watch racists chant slurs and messages of hate directed at Muslims, acting like the terrorists who we claim are our enemies and who we vow to defeat, those we are at war with-

ISIS- appreciates our help with their recruiting.” [38]

If one thinks about it, the road to radicalism can occur because of hatred; if a Muslim is persecuted so badly by members of other faiths, that person can reject all other faiths as viable ones and may see their beliefs as the only possible true faith. This can lead some Muslims to start interpreting the Quran in a very literal way, and this is where ISIS will step into that person's life. ISIS becomes more powerful every time they are brought down by Western ideology and repressed, as the article from the Atlantic, “Why Join ISIS? How Fighters Respond When You Ask Them,” shows us that many fighters join the radical group as revenge seekers, or of Identity seekers, who are “Prone to feeling isolated or alienated, these individuals “often feel like outsiders in their initial unfamiliar/unintelligible environment and seek to identify with another group.” Islam, for many of these provides “a pre- packaged transnational identity.” [39]

After researching how social isolation affects a human's mind, it is not very surprising that ostracized Muslim members join ISIS. In the BBC article, “How extreme isolation warps the mind,”

Micheal Bond describes how people subject to loneliness and community with other people experience psychological issues, and also suffer from many other health conditions like high blood pressure.

Notably, people who suffer from isolation will have a reduced sense of logical reasoning. Near the end

38. (Marshall, L, 2015) 39. (Tucker, P, 2015) of the article, this is attributed to the fact that as a primate, humans cannot interact with others very well if they have been outcast by other humans or have not had any experiences with other humans.

One famous experiment involving rhesus macaque monkeys, a species of primate very similar to humans, showed that when the monkeys were taken from other monkeys for either months or years, when they returned to the community were not capable of interaction with the other animals. [40]

Americans unfortunately associate the Muslim with an ISIS member or other terrorist group far too often, and this misconception further contributes to the isolation of Muslim people from the rest of society. In Graeme Wood's article, “What ISIS Really Wants,” Woods discusses where ISIS originated from, and debates on whether or not the group is truly Islamic, a controversial debate that has been pondered over by many other great scholars, such as Jessica Marglin, a writer for the Huffington Post who talks about how Islam, the religion itself, needs to be regarded as completely distinguished from

ISIS, which she claims are not one and the same. [41]

Marglin discusses that in the wake after 9/11, citizens worldwide contemplated whether or not

Islam is a violent religion, so they could find a reason for why 9/11 occurred in the first place. In Deepa

Kumar's book Islamophobia, she tells us that the amount of Qurans sold internationally dramatically shot up as people tried to determine whether the violence in 9/11 occurred solely because of the Islamic faith. [42] [43] Marglin also brings up how many people have different interpretations on whether or

40. (BBC, 2014) 41 (Wood, G, 2016) 42. (Marglin, J, 2015) 43. (Kumar, D, 2012) not ISIS is really Islamic or not- Most Muslims themselves even refuse to accept members of ISIS as

Muslims, because they feel that ISIS runs against Islam's core beliefs. The word Daesh is used instead of ISIS quite frequently so that it does not get interpreted as a true Islamic state. Marglin ends her article with a critical question for the audience:

In some ways, the distinction between ISIS as Islamic or not comes down to what you mean by “Islamic”: is it what Muslims do, or are there things Muslims do that put them outside the boundaries of the Islamic tradition? Either way, there is no justification for labeling an entire religion as violent merely because some of its adherents embrace violence, as do those who see Islam as the problem. This is particularly crucial now, when the New York Times publishes a headline stating that “After Paris, a Darker Mood towards Islam Emerges in France” and when the United States congress passes a bill to drastically tighten the screening procedures for Syrian refugees in what has been widely labeled the worst refugee crisis since WWII. Even if you consider ISIS Islamic, we must resist any temptation to conflate ISIS and Islam. [42]

Going back to Kumar's work, Kumar describes how most Muslims don't want to consider ISIS as Islamic because they don't want to look like they are the problem, and they want to avoid seeming like terrorists because of the actions of a minority group which claims to be Islamic. The problem is that it is very difficult to invalidate someone's beliefs for them. Although ISIS has definitely done things that most would consider heinous actions, this does not mean they are not Muslims any less than other groups of Muslim people are. When Timothy McVeigh, a fundamentalist Christian, blew up the federal building in Oklahoma, people were quick to argue that he was not a real Christian, and that no true Christian would ever do such a thing. However, the problem with this is that McVeigh could have been doing this action for his beliefs in his view of seeing his own faith. [43]

42. (Marglin, J, 2015) 43. (Kumar, D, 2012) In Andrew Gumbel's article, “Oklahoma City Bombing: 20 years later, key questions remain unanswered,” Gumbel writes about how the biggest question left was how many people were involved in the whole crime. For example, Terry Nichols created the bomb out of fertilizer for McVeigh, but during the trial, McVeigh insisted that there was other people involved in the bombing, but the FBI refused to continue with more investigation.

Another factor to note in Gumbel's article was that McVeigh was a former Army soldier, and

Nichols served alongside him, but neither of them were trained in the army well enough to create such a large weapon- meaning that more were involved in the hateful attack on the building; according the the article's words, “We don't know the identities of the other people seen with McVeigh on the morning of the bombing-only that more than 20 eyewitnesses were unanimous in telling the FBI he was not alone.” [44]

The latter statement could perhaps mean that many other Christian fundamentalists were involved in the Oklahoma City bombing, and the majority of the perpetrators in this crime were most likely of caucasian descent. This would signify that Islamophobia becomes worse when combined with skin color as well, and not just only clothing.

In an article by Simran Jeet Singh of The Daily Beast titled, “Flying While Sikh: Why Racial

Profiling Matters,” Singh discusses his experience through the American airport security while in his

Sikh attire, and while also appearing to be of Middle Eastern descent. He talked about his family experience being difficult already as they went through regular security screenings, which already seem

44. (Gumbel, A, 2015) to be a violation of privacy, and then explains how in the San Francisco airport, the TSA went too far and were in breach of national policy when they attempted to pat down his turban during a secondary screening. Singh states of this incident;

It was the most degrading moment of my life. I view my turban as a crown, something that connects me with my religion's deepest values, such as love, justice, and service. It shook me to the core that our nation, which was founded on the premise of freedom of expression and religion, was supporting and enforcing practices that went against those very principles. [45]

The unfortunate fact is that Singh's experience with a governmental agency (TSA) was not very extraordinary, especially considering that the United States has consistently kept policies which are based on racial profiling throughout its history. In the Racial Equity Tools workbook, “Race, Power, and Policy: Dismantling Structural Racism” by Sandra Hinson, Richard Healey, and Nathaniel

Weisenberg, the group first discusses how racism is not a static subject, and constantly changes as time goes by. For example, in 1789 only white people could be classified as citizens in the United States, but currently people of color can be classified as citizens as well. [46]

Even though in the United States a person of color is indeed a citizen, this does not stop the federal government from maintaining a societal structure in which simple white people are on the top of the hierarchy, and anyone else, especially people whose tradition is to wear religious clothes, are on the bottom of the heap. The colloquial term for this phenomena is called .

45. (Singh, S.J. and simran-jeet-singh, 2013) 46. (Race, power and policy: Dismantling structural racism prepared for national people’s action by the grassroots policy project, no date) The Washington Post article by Christine Emba, “What is white privilege,” explains the phenomena through its many examples, and how it affects people who are white, and how it affects people of color as well. Emba states that;

It's the level of societal advantage that comes with being seen as the norm in America, automatically conferred irrespective of wealth, gender, or other factors. It makes life smoother, but it's something you would barely notice unless it were suddenly taken away- or unless it had never applied to you in the first place. [47]

One key example Emba showed us of white privilege is of going shopping and not being followed or harassed by someone else. This is a very current issue, and the phrase “shopping while black” sums this issue up very brilliantly. In the International Business Times article by Catherine

Dunn, “Shopping While Black: America's Retailers Know They Have A Racial Profiling Problem. Now

What?,” Dunn describes Cheryl Johnson's traumatizing experience being accused of shoplifting at a

Belk store by a white woman. Johnson was allegedly brought upstairs in the store to a room where she was interrogated by security personnel with guns. Jackson felt compelled to tell her story of how she was singled out specifically for her race, along with many other citizens of color. A Gallup poll even found that African Americans in particular felt the most discriminated upon in a grocery store setting, when compared to a police stop or a restaurant.[47] [48]

However, even though the Gallup poll showed that it was primarily African-Americans who were more likely to feel more discriminated against in public settings, members of the Arab, or more precisely, Muslim community are nowhere near excluded from this horrendous bias. David Boroff's

47. (Emba, C, 2016)

48. (Dunn, C., Abrams, A. and Silva, C, 2015) Daily News article, “Muslim couple in Arkansas booted from mall after exhibiting 'very strange' behavior, cops say,” explains how a couple from Oklahoma, were removed from their local mall when the couple was accused of taking recordings of other citizens in the mall, and were promptly reported to the authorities.

The couple, hereby known as the Crawfords, claimed innocence to any suspicious activity, and stated that;

We purchased about $200 worth of Sperry shoes, which I'd be happy to show everybody,” he told the station. “There's nothing better than Sperrys. These things last about two to three years a piece and some beautiful Armani glasses from Lens Crafters. And these are the crimes we committed at the mall this weekend. [49]

This response from Alan Crawford in the incident was after the couple, with their young son, were detained by police and then escorted out of the mall. In Anthony Cox's police report of the incident, he states that;

One of the subjects told me that she thought he was acting very strange,” and “I spotted the subject walking down the hall by the food court and he was holding his phone up and he was walking as if he was video taping the mall stores. [49]

Crawford does not deny recording while in the mall, and in fact acknowledges it, stating that the rule was not clearly posted in the mall, and that his family merely were handing out information regarding a local charity and simply shopping for the holidays. The Sergeant of the police station in

49. (Boroff, D, 2015) Fort Smith, officer Daniel Grubbs, condones the actions of the other Fort Smith officers, telling Daily

News that; “You can take race, religion and sex out of the equation,' and “Any suspicious activity, you encourage citizens to come forward with it.”

It could be argued however that religion and race is most certainly a part of the equation in this situation when Cox's police report states that; (Crawfords ID) “was in his front pocket and it was against his religion to pull up his 'Man Dress' to get it, according to the police report.” Cox's statement is obviously offensive; it is specifically directed towards Alan Crawford's choice of clothing, which is a

Muslim man's garb, and degrades the meaning and significance of the Muslim outfit which holds many key values for many members of the Muslim society. [49]

One could also argue that Sergeant Grubb's response to the incident was strikingly similar to the response towards Muslims after 9/11 in the infamous If You See Something, Say Something act. In Anu

Joshi's Huffington Post article, “The Dangers of “See Something, Say Something,” Joshi describes how the movement has caused many civilians to be harassed by the US Government, and wrongfully put on watchlists nationwide, in a system where being suspicious is based on doing anything other than what society has normalized as a nation. Joshi tells us that,

Unfortunately, the federal government has doubled down on broad surveillance (and harassment) or marginalized communities in the wake of 9/11. Most notably, the government has deputized untrained civilians to further their surveillance reach through the now ubiquitous “See Something, Say Something” ad campaign. This desire by the government to cast a wider net to identify and respond to “suspicious behavior” has only heightened the risk of unfair and unjust targeting of marginalized individuals. [50]

49. (Boroff, D, 2015) 50. (Joshi, A, 2016) What Joshi means in this quote is that because the American nation as a whole has started to adopt surveillance in communities, regular citizens can become much like vigilantes in any so called suspicious situation, and an untrained person can deem a situation as extremely dangerous, even when there is not truly an imminent threat to themselves or to other people. However, when thinking about this, one runs into the problem then of whether or not police officers are trained well enough to handle surveillance issues, and whether or not they are further agitating already dangerous waters. [50]

The American Civil Liberties Union article, “Surveillance By Other Agencies,” sheds more light on American surveillance of minorities nationwide, and explains how this surveillance is actually very detrimental not only to the minorities, but to the majorities as well. The ACLU shows us that the biggest problem with state or federal surveillance is that; “Unchecked spying on Americans not only invades their privacy but also floods law enforcement agencies with useless information on innocent activity, making their jobs harder. It makes us neither safe nor free,” and “The Transportation Security

Association (TSA) employs thousands of “behavior detection officers” who scan passengers in the screening areas of airports for signs of deception or “mal-intent”- a program that the government's own watchdog has concluded is based on junk science and is a waste of money. [51]

And the former statement would be absolutely correct, according to David A. Graham's article,

“The TSA Doesn't Work-and Never Has.” Graham's article primarily explains how the TSA can only make people feel safe, through what has been deemed a “security theater.” The TSA has failed to recognize many real potential threats, and dangerous weapons have gone by completely unnoticed by

50. (Joshi, A, 2016) 51. (ACLU, 2016b) members of the organization. One significant example of this was when undercover agents attempted to smuggle in weapons through the airport;

An internal investigation of the Transportation Security Administration revealed security failures at dozens of the nation's busiest airports, where undercover investigators were able to smuggle mock explosives or banned weapons through checkpoints in 95 percent of trials, ABC News has learned. The series of tests were conducted by Homeland Security Red Teams who pose as passengers, setting out to beat the system.[52]

Most people know the security check protocol, and have gone on enough flights to know that the screening process can be a bit too quick for it to be thorough enough, even when one is pulled to the side for a patdown, the TSA can still miss important items in a person's clothing, like the Red Team member's fake bomb strapped to his back. Former TSA administrator John Pistole claims that viewing the TSA in a bad way because they could not catch the Red Team Member's weapon paraphernalia is ridiculous, as he felt that the Red Team already knew everything about the TSA to easily sneak through the security officers with their fake weapons. [52]

Pistole does make a good point in that the Red Team is not like regular passengers. The Red

Team had a specific goal to smuggle their weapons through the checkpoints, and also had in-depth knowledge of how the TSA security works.

However, Graham would argue that “regular” passengers themselves have smuggled illegal

52. (Graham, D.A, 2015) items through airports, and Graham even cites his own colleague Jeffrey Goldberg as having done this, with an excerpt of his article, “The Things He Carried,” stating that;

Because I have a fair amount of experience reporting on terrorists, and because terrorist groups produce large quantities of branded knicknacks, I've amassed an inspiring collection of al- Qaeda T-shirts, Islamic Jihad flags, Hezbollah videotapes, and inflatable Yasir Arafat dolls (really). All these things I've carried with me through airports across the country. I've also carried, at various times: pocketknives, matches from hotels in Beirut and Peshawar, dust masks, lengths of rope, cigarette lighters, nail clippers, eight-ounce tubes of toothpaste (in my front pocket), bottles of Fiji water (which is foreign), and, of course, box cutters. I was selected for secondary screening four times- out of dozens of passages through security checkpoints- during this extended experiment. At one screening, I was relieved of a pair of nail clippers; during another, a can of shaving cream. [53]

Goldberg's experience through airports nationwide means that anyone really could be a

“terrorist,” especially when we note that Goldberg was only taken aside for secondary screening a mere four times, out of the dozens of trips he went on. After the incident, Homeland Security did try to ameliorate the situation, with Graham telling us that;

Secretary Jeh Johnson reassigned the administrator of TSA, Melvin Carraway, with a curt valediction: “I thank Melvin Carraway for his eleven years of service to TSA and his 36 years of public service to this Nation.” Except that Carraway wasn't really the administrator- he was the acting administrator. The last permanent administrator, John Pistole, left on New Year's Eve 2014, leaving the agency without a leader. It took the administration until the end of April to nominate a new administrator, in part because there was great concern to bring in someone who could get confirmed by the senate. [53]

This statement shows us that the TSA does not even have a solid framework for their organization, as they don't even have their leaders figured out well enough, and also that it takes them

53. (Goldberg, J, 2014) far too long to assign new leaders for the administration. [52] [53]

Adding insult to injury, the TSA is not only inefficient, it is also incorrigibly racist.

The Daily Orange article, “Report of TSA behavior shows racist tendencies,” by Harmen

Rockler, Rockler writes about the TSA's action to observe passengers behaviors who may be potentially threatening, but are mostly people in minority groups. Rockler writes this article using the

Boston Logan airport as an example.

Rockler states that the Boston Logan Airport has been doing passenger behavior screening as early as 2003, and finally in 2011, the official program of behavior tracking was launched at the airport, which served approximately 1,865, 357 passengers in January 2011. With an airport traffic that high, it is not surprising that there is constant paranoia over terrorism and violence, especially in a large northeastern metropolis very close to ground zero in Manhattan. Rockler states of this that;

Some think we need to profile. Supporters of racial profiling proclaim we shouldn't sacrifice our security for political correctness. Because the 9/11 hijackers looked Middle Eastern, we need to heavily screen those who look similar. Law enforcement officers' instincts should be pursued so we can be safer. Not all terrorists who attack the United States have been Muslim or even look Middle Eastern. White and nonwhite individuals have committed acts of terrorism on U.S soil. All individuals should be equally, fairly scrutinized at airport security because anyone could pose a threat- no matter his or her race. Trying to more heavily screen people who look Arabic is not only a poor response to the actual threat posed, but it may do further damage to the ability of law enforcement to protect us from actual threats. We risk alienating the people we need to help us. [54] [55]

52. (Graham, D.A, 2015) 53. (Goldberg, J, 2014) 54. (Sugiyama, S, 2016) 55. (Boston-Logan international airport, no date) Rockler in her statement seems to be trying to tell the audience that Arabic looking people are also necessary in the fight against terrorism in the United States, and that when groups such as the TSA single out Arabic or other Middle Eastern appearing people- they could be missing the white terrorist plotting to take down the next flight to Los Angeles. Many people forget that even people who would appear to be in the cultural 'norm' can be terrorists as well; going back to Timothy McVeigh and the

Oklahoma City bombing in 1995, we can easily see that McVeigh doesn't appear to look very different from most average white male citizens in the United States. In his mugshot posted on the Business

Insider article titled, “20 years after the Oklahoma City bombing, Timothy McVeigh remains the only terrorist executed by US,” by Ryan Gorman, we can see that McVeigh was a fair skinned man who looked to be close to middle age, most people in the United States would not give Mr. McVeigh a second glance, because he is of the majority; however, since he was in he army at one point in time, many arguments claim that he is not a terrorist, and is mentally ill. [56]

According to BBC News Article, “Inside McVeigh's Mind,” by Robin Aitken, Aitkin explains how following the Oklahoma City Bombing, McVeigh was tested by a psychologist, and the results showed that McVeigh may have suffered PTSD, but Aitkin tells us that;

In Dr Smith's opinion it was events at Waco in Texas in 1993 that were a critical turning point for the young ex-soldier. Federal agents surrounded and eventually stormed the compound of an obscure religious sect- the Branch Davidians. About 80 people- 17 of them children- died during the confrontation. McVeigh, who was also deeply concerned by federal government attempts to restrict gun ownership, strongly identified with the victims at Waco, said Dr. Smith. To McVeigh, the federal government became “the ultimate bully”. It was then that McVeigh conceived the plan to bomb the federal building in revenge for Waco. The attack- which took place exactly two years after Waco- killed 168 people, 20 of them children.[57] 56. (Gorman, R, 2015) 57. (BBC, 2001) Some important information to have in mind is the context of the Waco 1993 incident, also known as the Waco Siege or Waco Massacre, was that it was an incident fully instigated by the

American Federal Government. The CBS News article, “What Really Happened At Waco Six Years

Later Controversy Continues,” asks whether or not government agents were responsible for the deaths of 70 children, men, and women in the siege, which occurred on April nineteenth, 1993. While this opinion has often been claimed as just an anti-government conspiracy theory, CBS News shows that the theory may in fact be plausible, if not completely true. CBS News tells us of the evidence that;

The attorney general and the FBI as a whole have consistently maintained the government did not fire a single shot that day. Caddell says that the proof lies in video shot by a camera aboard an FBI aircraft, a het (sic)- detecting eye in the sky known as a forward- looking infrared.” Attorney Caddell believes it tells the story. “What we see on numerous occasions,” says Caddell, referring to the videotape, “is an ongoing gun battle between government forces and the Davidians.” Caddell claims that the flashes of heat recorded by the sensitive camera are evidence of someone shooting into the compound in response to Davidian gunfire. They began late in the morning and continued a little after noon. [58]

The context is important to note for McVeigh's case because it may have made him feel as if the entire American government failed him, just like many Muslim people feel as if the American government claims to be helping and supporting the Muslim community and Arabian people, but the

American government has too much history with racism since its birth in 1776 to make such big claims.

Diving into the New York Times article, “White Terrorism Is as Old as America,” by Brit

Benett, we are shown why terrorism should not be seen as only done by people of a particular race, but

58. (CBSN, 2000) rather that terrorism is what people in general do, including white people particularly. Benett first starts by using a personal anecdote about her grandmother's experience with racism during the movement, and how the slaves could see the members as people they recognized. Some of the Ku Klux members would claim to be ghosts of the Confederate army, who wanted to seek revenge by annihilating African-American people completely. Benett claims of this that;

You could argue, of course, that there are no ghosts of the Confederacy, because the Confederacy is not yet dead. The stars and bars live on, proudly emblazoned on T-shirts and license plates; the pre-eminent symbol of slavery, the flag itself, still flies on the grounds of South Carolina's Capitol. The killing has not stopped either, as shown by the deaths of nine black people in a church in Charleston this week. The suspected gunman, who is white and was charged with nine counts of murder on Friday, is said to have told their Bible-study group: You rape our women, and you are taking over our country. And you have to go.[59]

The suspect, Dylan Storm Roof, is showing a xenophobic tendency which many people have towards others of different races, particularly ones which have been stereotyped as criminals, etc.

The article by the American Society for Public Administration's (ASPA) article, “, the Other Face of Racism,” explains how although America claims to be a place for immigration, and a so called “melting pot” for all people, xenophobia has become rampant in American society following much of its globalization, as new thoughts and cultures merge together and attempt to mesh into

American life.

Unfortunately, many citizens in America are wary about foreigners being introduced into

59. (Bennett, B, 2015) the country, and fear what they could do, or are hostile towards foreigners because of what their country has done. The ASPA's best example for this is that of an Iranian trying to immigrate into the

United States post Iranian Revolution or an Iraqi citizen;

If the newcomer, for example, is from a country or region that has produced an intense political event that is still stressing, that person might be prioritized by xenophobia as hate target number one simply for guilt by regional association with the generating region of such tension. An Iraqi, for example, may be regarded as such simply because of Iraq's recent political stress in relation to US national security. The next in ranking would be someone who is from a region or a country that is producing a stressing political tension with the United States that seeds within a recent historical context. An example would be someone from Iran (with the Iranian Revolution of 1979 constituting a stressing recent political history and continues to escalate in its tension, especially in relation to the issue of nuclear weapons. [60]

The Iranian Revolution in 1979 heavily stigmatized Iranian people as a whole, and a search of images shows the solid proof; one image of a man wearing a cloth over his head and holding a large shotgun is something that would cause an American audience great fear; first you have the mysteriousness of the man's mask that he is hiding under. This is important to note because if someone does not know who this person is since they can only view the eyes and mouth, it could potentially be someone they know, and it is someone who could get away with an action if not properly identified.

Many people associate the hijab as being a sign of wickedness or as a suspicious garment for this same reason as well. For example, in a niqab, you cannot see the majority of the woman's face who is wearing it, and you can only see her eyes, which could almost seem sinister to people in a way, since it is unusual in the American normative for people to cover their faces, effectively making hijab wearers outsiders and targets of xenophobia. [61]

60. (Dawoody, A, 2010) 61. (Sputnik, 2015) This xenophobia towards hijab wearers only gets worse following an event in which the blame is placed on a Middle Eastern country. In the article by Leslie Berestein Rojas called, “Climate of fear has some Muslim women making difficult decisions about wearing hijab,” Rojas describes the choices of a few Muslim women who had to decide whether or not to wear the hijab after the Paris Attacks in

2015. If choosing to wear the hijab, many women had very negative repercussions. For example, Maria

Ahmed's experience following the Paris attacks encouraged her to keep her hijab on, because she wants to set an example for her children that Muslims are not doing anything wrong by choosing either to wear or not to wear the hijab. Ahmed says of this;

I want them to know not to be afraid, Ahmed said, talking about her children. I want them to know to stay strong, remember who they are, know in their hearts that they're not doing anything wrong. And if some people choose to judge you, then that is their loss, that they don't get to know you. You still do your best, you still do your part. [62]

Morally, its easy to say that no person should ever feel they are doing wrong by wearing the hijab or any other form of religious clothing. From a moral standpoint, most countries require for their citizens to wear clothing, and the choice of clothing a person wears is either their choice, or a certain outfit that is required by a dress code. People may use clothing to show their wealth or other statuses to the world around them, which helps create this otherness to Muslim clothing. Take for example, a white woman wearing a T-Shirt and jeans with a brand name of sneakers. This sounds like a pretty typical

American woman. Next, take for example an Arabian woman wearing a niqab, with no brand name clothing and only an abaya, a traditional Muslim dress for women. To Americans, the Arabian woman would appear completely strange, and she would be an outcast of the “normal” group of society. Her clothing may even be discriminated as appearing poor to other people, as social hierarchy and

62. (KPCC, 3 and Radio, S.C.P, 2015) branding go hand in hand.

In the ABC News article, “Explainer: Why do Muslim women wear a burka, niqab, or hijab,” author James Vyver explains how the religious garments a woman can wear while practicing Islam are all very unique, and how lately women have been criticized for wearing these garments because of

ISIS' actions, and they are protesting this using Twitter and other social media platforms as the

#NotInmyname movement. Dr. Ismail, a teacher of Middle East Politics and Islamic Studies at the

Australian National University, describes her experience wearing a hijab with;

Once in a while, people call me a terrorist. My first experience in Australia [involved] two women behind me who said, 'They are everywhere, it's like a disease,' “They pushed me a little bit and started laughing. I was so heartbroken.” Though confronting and upsetting, Dr. Ismail said this kind of experience is in the minority, and “In Canberra people are so lovely; sometimes people just smile at me, and that is just so nice, she said. [63]

Dr. Ismail's example may perhaps mean that in different regions of the world, people may have either better or worse reception of traditional Muslim clothing. Her example of Canberra seems to show us that Australia in general may be less xenophobic than say, America is towards hijab.

America is not alone in its xenophobia towards the Muslim people, and France is currently also a major player for racist policy in the world against Middle Eastern people. In Carla Power's TIME article, “Why There's Tension Between France and Its Muslim Population,” Power explains how

France likes to keep the country completely secular and religion neutral is making it difficult for

Muslim people to fully express their faith. Power tells us that this neutrality is problematic because the

63. (Vyver, J, 2014) Islamic faith requires believers to express their faith publicly. This neutrality even goes into the education system of France, Power tells us when she says;

And in 2013, the government launched what it called a Charter for Secularity in School, a set of guidelines on 15 key points of secularism to be posted in classrooms as an attempt to keep religion out of school. The then-government education minister, Vincent Peillon, insisted it was an attempt “to get everyone together,” but it had the opposite effect, with Muslim leaders claiming it stigmatized their community. [64]

The Charter for Secularity in School, denies students in French schools of many of the rights they should have. Under the charter, a religious person cannot go against the rules to follow their own faith, cannot wear religious symbols, and teachers themselves cannot show their own religious beliefs when teaching their pupils. [65]

France has become a more secular country for many various reasons; the first reason is that secularism, called laicete in French is actually intended to protect people in France, and is not intended to be against people who actually practice different faiths, the Guardian article, “France to overhaul secularism teaching to help stop radicalisation,” by Angelique Chrisafis, tells us.

However, France in 2004 decided to become a completely secular republic in which wearing headscarves to schools and other public institutions was forbidden, and the only justification for this was all schools need to be freed from religious beliefs.

In her article, Chrisafis interviews Najat Vallaud-Belkacem, a womens rights activist and a

64. (Power, C, 2015) 65. (Samuel, H, 2013) former candidate for French presidency. Belkacem tells us of how she sees laicete;

Laicete is about saying we're in a country where individuals can have whatever beliefs, or lack of beliefs, they choose and the public powers must be neutral towards them. That's why in schools, we ask pupils not to wear distinctive religious symbols, because schools should be indifferent to beliefs and everyone must be treated equally. But there had been a growing sense of incomprehension among pupils over what this meant, with some pupils feeling it was an aggressive attack on who they were. [66]

Using Belkacem's viewpoint, Belkacem is arguing in the way that one would argue for dress code in schools. Her argument seems to be hinting that if there are absolutely no distinctive religious symbols on a student, they will be treated as exactly the same as other students in the school, but this logic seems to be faulty. The first problem would be to determine what a distinctive religious symbol would be, and whether this is only tailored to very obvious symbols such as a headscarf or niqab. A small Christian cross necklace may not even be very noticeable comparatively, but other students may notice it, and the student wearing said necklace may form cliques with like students, whereas a student wearing a hijab will be far too noticeable and will be asked to remove it.

The next problem is that if students cannot freely wear their religious symbols in schools, they are therefore not fully able to express their faith, in all its aspects. The New Republic Article by

Elizabeth Winkler, “Is it Time for France to Abandon Laicete?” explains that even though laicete was created to ameliorate religious divisions between citizens, it has only caused the divisions to grow even wider. Winkler says of this that;

66. (Chrisafis, A, 2016) As France marks the one-year anniversary of the terrorist attack on the offices of Charlie Hebdo, French officials are stepping up efforts to counter violent extremism. One measure involves widening police powers to conduct raids and detain suspected terrorists. The Supreme Court is reviewing a draft bill that would make these temporary, state-of-emergency tools, implemented after the November 2015 attacks on multiple sites in Paris, permanent. The state- backed Conseil Francais du Culte Musulman (French Council of Islam) has also announced its intention to issue certificates to imams who acknowledge French values and demonstrate their non-radical credentials. Some worry that such measures will play into the hands of the Islamic State and other extremist groups. Increasing police powers could endanger respect for civil liberties, while imposing governmental control of Islam in France could drive more Muslims to radical sects. [67]

Unraveling this statement, we can immediately see how problematic France's decision to make the state-of-emergency tools permanent would be. With this scenario in mind, no Muslim citizen in

France would likely ever feel safe, as they could be deemed a terrorist or radical for practicing what they believe in, even if it does not involve any true crime. For example, if a Muslim person were taking part in prayer multiple times a day at certain intervals, this is not radical in any shape or form, just as wearing hijab is not itself a symbol of radicalization, and should not be seen as a threat in any way. If a

Muslim citizen was however, threatening someone who does not believe in Islam, or actually committing a true crime in the name of their faith, then that indeed would be a radical.

If we look up the words radical or extremist, we find that radical means, “having extreme political or social views that are not shared by most people,” while extremist means, “belief in and support for ideas that are very far from what most people consider correct or reasonable.” [68] [69]

This brings up a crucial question: Is France actually basing a law off of social norms? By the

67. (Winkler, E, 2016) 68. (Merriam-Webster, 2015) 69. (Merriam-Webster, 2015a) definition of radical, it would appear this way. Many laws throughout history have been based on many societal norms and expectations of the people in the community. This is why in other countries, the laws are different, and if someone travels to said country, they are bound to that country's laws, and not the laws of the country they previously came from.

The article by The Judicial Learning Center, “Law and the Rule of Law,” explains how laws were created with a civilized society in mind, to protect the people of any country, like from gender discrimination or religious discrimination, and laws in many countries involve safety purposes, such as food quality laws, and non trespassing regulations. The article states of laws that;

Laws are rules that bind people living in a community. Laws protect our general safety, and ensure our rights as citizens against abuses by other people, by organizations, and by the government itself. We have laws to help provide for our general safety. They exist at the local, state and national levels, and include things like: Laws about food safety. At the state and local level, health departments have guidelines that restaurants follow for how to store and prepare food in a healthy manner, so that diners won't get sick. At the national level, the department of agriculture and other federal agencies inspect food production plants to be sure that the food in your supermarket is safe to eat. Speed limits and traffic laws exist so that we drive in a safe manner. Licensing for doctors and nurses ensures proper training of the people who look after us, and who often have our lives in their hands.We also have laws that protect our rights as citizens, and which include things like: Laws that come from the Bill of Rights in the U.S. Constitution, that guarantees our basic freedoms like freedom of speech, religion, and the press. Laws that protect us from discrimination because of our race, gender, age, or because of a disability. [70]

Although this definition of a law is based completely off of United States law and is therefore a bit ethnocentric, generally the purpose of a law is very consistent. Laws are not typically made to simply prevent citizen's freedom, they are made in order to keep all citizens safe, healthy, and civil towards one another. For example, in most societies, murder (homicide) is completely illegal, and the

70. (Judicial Learning Center, 2015) penalties for this crime are usually the most severest that the government can give to the perpetrator.

However, in select societies, such as Pakistan, honor killings or shame killings are not illegal and happen far too often. Honor killings make other countries seem to discriminate against the entire nation of Pakistan and other Islamic based countries, but these countries do not seem to understand the entire picture. Honor killings are often done by another family member, and according to the information the article “Defending Pakistani women against honour killings,” by Aurengzeb Qureshi provides us,

Qureshi states that;

Honour killings in Pakistan are more common than one might assume. The Pakistan Human Rights Commission 2014 annual report states that more than 3,000 women (PDF) have died in so-called honour killings in Pakistan since 2008. The Aurat Foundation, a rights group in the country puts estimates even higher and maintains that these incidents claim the lives of 1,000 women every year. A 2011 study (PDF) by the the (sic) Aurat Foundation found that the Criminal Law (Amendment) Act 2004, otherwise known as the “Honour Killings Act” that makes so-called honour killings punishable by law did little to decrease the incidence of such crimes.[71]

Looking at the statistics, we can see that the rate of honour killings in Islamic countries is steadily growing, and doesn't look like it will change anytime soon; The perpetrators of honour killings in Pakistan seem unfazed by the threat of punishment for their crime. This is because much of the law in Pakistan is based heavily off of family custom, and this meaning a patriarchal system, in which women of the family must live their lives as chosen by their other family members, be it arranged marriage, or not allowing a woman to leave the house, or she can be punished by execution. [71]

Going back to laicete, it makes a bit more sense that a country might want to exclude religion

71. (Network, A.J.M, 2016) from its schools and other places. There is fear that damage could occur to citizens, and there is fear that the citizens will become oppressed if religion is allowed to enter the school system along with other places. In Robert Zaretsky's article on Foreign Policy titled, “How French Secularism Became

Fundamentalist,” Zaretsky describes the difficult conflict between terrorism, and the French notion of secularism. Zaretsky first explains laicete as being very similar to the First Amendment in the U.S

Constitution, and tells us that;

In 1905, when France's Third Republic enacted the separation of church and state, it offered a simple definition of the term. Laicete :assures the liberty of conscience” of all French citizens, the new law read. This law was given further elaboration in the constitution of the Fifth (and current) Republic: Laicete “assures the equality of all citizens before the law, without distinction to their origin, race, or religion. It respects all religious beliefs.” There was essentially no substantive difference between the style of secularism envisioned by the founders of laicete and the framers of the First Amendment to the U.S. Constitution. As in the United States, French Secularism initially sought to ensure religious pluralism in the public and private spheres- nothing more, nothing less.[72]

To understand Zaretsky's statement, we need to understand what religious pluralism means. The

Pluralism Project website of Harvard University states that religious pluralism or diversity is not simply about the diversity and different forms and practices of religion, but rather that it is the way people connect with this diversity, how people are empathetic to others and understanding of their diversity, and how diversity should be shared across different lines of people in a community. [73]

72. (Rothkopf, D., Jacinto, L., De Luce, D., Hudson, J., Twining, D., Holmes, J., Knights, M., Francis, D., O’Grady, S. and Zaretsky, R, 2016) 73. (President2016–•, Harvard, F. of and Eck, D, 1997) Given that France has officially banned hijab in schools, France does not in any way work towards religious pluralism. This is because taking away the hijab was an action of misunderstanding and misrepresentation, and did not take into account how it would affect the Muslim believers in the community. The new form of secularism also prevents people from expressing their diversity to other people in France. If the laicete is intended to be like the First Amendment in the U.S. Constitution, then why is this law not as strong as it could be to protect Muslims from discrimination, and also why is it creating further harm to the Muslim people by preventing them from their rights?

In the Financial Times article, “Hardline secularism will not solve France's problems,” by

Sudhir Hazareesingh, Hazareesingh explains how the French concept of laicete is incredibly recent, having officially started in 1905, and the law still currently does not have rule over all districts of the country, one good example being Alsace-Mosele.

The age of the law is important to note because currently the law of laicete demands for a homogenous society in France, 111 years later; this is striking because France should have gotten rid of this law a long time ago and replaced it instead with a law that embraces diversity, and perhaps even encourages diversity, including religious diversity. Hazareesingh states of the current laicete in France;

More recently, laicete has been cited as justification for banning the niqab, the face-covering veil; questioning the provision of alternatives to pork in school canteens; and even demanding Muslim mothers collecting children from school be prevented from wearing the hijab. The extreme-right National Front has adopted laicete as one of its main slogans, conflating Islam with Islamism and appealing to the ideal of an ethnically homogenous French community. The divisive and stigmatizing use of laicete in this way has become common since the jihadi attacks on Paris in January and November last year. It is reflected in widespread calls for Muslims to “prove” their attachment to the nation. The notion that these men and women are not “properly” French underlies President Francois Hollande's extraordinary proposal to strip French citizenship from dual nationals found guilty of terrorism. Christiane Taubira, a notable opponent of the proposal, this week resigned in protest from her position as justice minister. The legislation was subsequently presented to a parliamentary commission without mention of dual nationality. [74]

Hazareesingh's mentioning of the National Front organization and Christiane Taubira is extremely significant for the progression of French laicete. The National Front organization has been described as an incredibly xenophobic right wing political campaign that is being run by Marine Le

Pen, who wants to become the French president in 2017, according to the Atlantic's article, “Le Pen

Will Be Mightier,” by Adam Chandler. According to Christopher Dickey's response to Le Pen from The

Daily Beast was a witty comparison to America's Donald Trump, who is very well known for his far right ideals and xenophobic tendencies. Dickey tells us of Le Pen;

Indeed, traditional politicians here regard Le Pen with something like the same horror that the American mainstream regards Donald Trump, and for some of the same reasons. Seen as sly, anti-immigrant, implicitly racist populists, both are portrayed in the political language of Europe as “fascists.” [75]

Although it may seem like a large stretch to compare Marine Le Pen to the American presidential candidate Donald Trump. In fact, the BBC article, Trump v Le Pen: In their own words,” by Avinash Chak, Chak shows us that Le Pen and Donald Trump have both done similar actions in response to terror attacks in their respective countries. Trump, following the San Bernadino massacre, called for complete immigration closure towards Muslim people, while Le pen stated that she simply

74. (Hazareesingh, no date)

75. (Chandler, 2015) wanted “an immediate end to all reception of migrants in France and an immediate end to their dispersal in the municipalities of France, both villages and towns.” [76]

One important thing to note is their similarities, and the propaganda like statements they try to broadcast for their prospective voters. In a way, it seems they are playing on the emotions of the citizens in their countries, more so after a terrorist attack or in their responses towards the terrorist group ISIS. Both Trump and Le Pen called for a violent response towards ISIS, with Trump stating that;

Nobody would be tougher on ISIS than Donald Trump. Nobody. I will find-within our military- I will find General Patton, or I will find General MacArthur. I will find the right guy. I will find the guy that's going to take that military and make it really work. Nobody, nobody will be pushing us around.

Marine Le Pen states in her response towards ISIS;

Bashar al-Assad leads Syria today, he leads an army, there is no other way if one wants to eradicate Islamic State than to join a large coalition including Bashar al-Assad... If I were president I would have done it three years ago. [76]

Both statements are not only alike in their basic structure which demands action be taken towards ISIS, both are similar in that they are not very practical solutions whatsoever. In Trump's statement, Trump seems to believe he himself will find a person to lead a military that will be strong enough to defeat ISIS. Not only is that an extremely arrogant egocentric idea, it leaves one thinking, if

ISIS seems to always get away with so many incidents, how would a group like ISIS be stopped?

76. (Chak, 2015) As far as Le Pen's statement goes, her wishes to have Bashar al-Assad be a member of a coalition against ISIS is far too wishy-washy; Bashar al-Assad is well known in his own country of

Syria to be a failure of a president. This is shown well in Raf Sanchez' Telegraph article, Bashar al-

Assad: I want to be remembered as the man who saved Syria,” where Sanchez tells us that Assad held a speech right before multiple car bombs exploded in Homs, with Assad believing that Syrian would simple become safe and sound again, which received intense criticism from many groups. Another idea to consider is that Mr. Assad himself is contributing to the downfall of his own nation by participating in barrel bombings across the already war-torn nation. [77]

The Al Jazeera article, “At UN panel, speakers call for end to Syria barrel bombs,” the article explains what barrel bombs are, and how they are perpetuated by Assad's regime. Al Jazeera's description of the bombs shows how it is connected to Mr. Assad, and how these weapons cause mass destruction and fatalities;

Barrel bombs are simple devices: oil drums packed with explosives and shrapnel that are rolled out the back door of high-flying Syrian military helicopters over opposition areas. The explosives detonate on impact and can bring down the seven- and eight-story residential buildings. The regime's unrestrained use of the indiscriminate weapons has led Syrians to nickname the improvised explosives barrels of death. The weapons have killed thousands of civilians over the past four years. [78]

Also, Le Pen and Trump have a connection in that Le Pen supports Trumps xenophobic views, and he stated that, “If I were American, I would vote Donald Trump, But may God protect him.” Jean

77. (Sanchez, 2016)

78. (America, 2015) Marie Le Pen has a notable history in that he was actually found guilty for contesting crimes of humanity; and his own daughter, Marine was acquitted from hate crimes towards the French Muslim community. [79]

The same goes for Donald Trump, who was accused of racial discrimination decades back in

1973. According to the report by the Washington Post titled, “Inside the government's racial bias case against Donald Trump's company, and how he fought it,” by Micheal Kranish and Robert O' Harrow Jr explains Trumps case of discrimination involving apartment rent for a black woman and for rent involving a white woman. Allegedly, when the black woman asked for an apartment to rent, the response was that there was no more available units to rent. However, when a white woman asked for an apartment to rent only a short while later, the white woman had the option to choose from two apartments.

Unfortunately for the Trump realty company, the two women were both sent to find out whether or not the realty company was being discriminate towards minorities in the Brooklyn and Queens region of New York. Because of these womens reports to the authorities, Federal investigators came to check out the apartment and found very damning evidence of racial discrimination on Trumps part.

What the Federal investigators had found out about the apartment complex was astonishing;

Trump employees had secretly marked the applications of minorities with codes, such as “No. 9” and “C” for “colored,” according to government interview accounts filed in federal court.

79. (Yuhas, 2016) The employees allegedly directed blacks and Puerto Ricans away from buildings with mostly white tenants, and steered them toward properties that had many minorities, the government filings alleged. In October 1973, the Justice Department filed a civil rights case that accused the Trump firm, whose complexes contained 14,000 apartments, of violating the Fair Housing Act of 1968. [80]

Going back to important players in the progression of laicete, Christiane Taubira was the French

Justice Minister who resigned shortly following Hollande's proposal to remove French dual citizens of their citizenship if they had been convicted of terrorism, the Guardian article, “French minister

Christiane Taubira resigns after fallout over terror policy,” by Angelique Chrisafis. Chrisafis states in his article that Taubira greatly opposed the proposal because she felt that citizens would take it with a mixed response since it could be argued that the proposal implied an hierarchy of pure French citizens over other citizens with mixed backgrounds and heritages. Before Taubira resigned, she had attended a parliamentary debate for the changing of the French constitution, and Chrisafis tells us of this that;

On Wednesday morning, just as parliament prepared to open its first debate on the constitutional changes, Taubira met Hollande and Valls at the Elysee Palace for a meeting that was described as “warm”. Hollande's presidential office swiftly issued a statement saying that Taubira had resigned. Taubira instantly tweeted: “Sometimes to resist means staying, sometimes to resist means leaving.” Her departure clears the way for the government to drive through changes to the French constitution that include the special security measures that make up the state of emergency. France has been living under a state of emergency since the November attacks and is now seeking to extend it until June. It gives police and local officials special powers to raid homes and place people under house arrest without judicial oversight.[81]

Looking at the last statement of Chrisafis' quote is very astonishing to think about. Just imagine

80. (Kranish and O’Harrow, 2016)

81. (Chrisafis, 2016b) if you were to be accused of a crime, and instantaneously dumped into a jail cell, without any actual proof that you had done anything illegal. This situation is the exact current state of France; unfortunately this condition has led to Muslim citizens being targeted after ISIS took full responsibility for the Paris attacks in late 2015. This should not be the case as I have described in the former pages of my essay; Muslim people, regardless of their status in their nation, need not be regarded as terrorists because of the actions of a few, and they deserve a fair trial just as other pure French citizens do.

Muslim citizens in the United States need to be recognized as an equal people, and need to be freed from the stereotypes and xenophobia that clouds peoples judgment over them, and firm laws need to be erected which establish a no tolerance policy for bias towards Muslim people.

In conclusion, my position is that both the French and The United States governments are inherently xenophobic towards the Muslim community, and policies need to be put into place that allow for the full expression of faith, without causing the Muslim community fear of recourse for their expressions of faith. As I have described in my comparison of banning the hijab to having a forced dress code in schools, both have been shown to be damaging to the people who must follow these xenophobic and anti free speech rules. For the hijab ban and discrimination, the oppression has been shown to lead to a rising number of recruits joining ISIS, while students following a dress code will still segregate themselves through other methods, such as wearing accessories which show wealth and popularity, among other statuses. One argument has been that allowing Muslim people to wear hijab will make them segregated to the rest of the community around them, but this has been proven to not be true. This is because people of all different kinds of backgrounds often segregate as well into noticeable groups and communities, making for a world which is less connected than it should be. Bibliography

1. ACLU (2010)Discrimination against Muslim women - fact sheet. Available at: https://www.aclu.org/discrimination-against-muslim-women-fact-sheet (Accessed: 2 April 2016). 2. Nasaw, D. (2008a) Georgia judge jails Muslim woman for wearing headscarf to court. Available at: http://www.theguardian.com/world/2008/dec/17/georgia-headscarf-courtroom-rollins (Accessed: 2 April 2016). 3. Duell, M. and Whitwell, L. (2011) Mass brawl at theme park after Muslim women are banned from going on rides unless they remove their head scarves. Available at: http://www.dailymail.co.uk/news/article- 2032031/Ramadan-brawl-Rye-Playland-theme-park-Muslim-women-banned-rides.html (Accessed: 2 April 2016). 4. Hudson, R. (2014)Being a cop showed me just how racist and violent the police are. There’s only one fix. Available at: https://www.washingtonpost.com/posteverything/wp/2014/12/06/i-was-a-st-louis-cop-my- peers- were- racist-and-violent-and-theres-only-one-fix/ (Accessed: 4 April 2016). 5. Bernish, C. (2016) So it begins: Cop threatens to arrest Muslim woman for wearing a Hijab. Available at: http://thefreethoughtproject.com/begins-cops-threatening-arrest-muslim-women-wearing-religious-clothing/ (Accessed: 4 April 2016). 6. KIRKA, D. and Press, A. (2015)ISIS is luring normal western women with troubling simplicity. Available at: http://www.businessinsider.com/young-women-are-joining-isis-for-more-than-marriage-2015-5 (Accessed: 4 April 2016). 7. ACLU (2016)Factsheet: The NYPD Muslim surveillance program. Available at: https://www.aclu.org/factsheet-nypd-muslim-surveillance-program (Accessed: 4 April 2016).Aziz, S. (2012) 8. Racial profiling by law enforcement is poisoning Muslim Americans’ trust. Available at: http://www.theguardian.com/commentisfree/cifamerica/2012/feb/21/racial-profiling-law-enforcement-muslim- americans (Accessed: 6 April 2016). 9. Edelman, S. and Schram, J. (2015) NYPD ready to settle case over spying on Muslims. Available at: http://nypost.com/2015/11/29/nypd-ready-to-settle-case-over-spying-on-muslims/ (Accessed: 6 April 2016). 10.Peralta, E. (2015) The Paris attacks: What we know right now. Available at: http://www.npr.org/sections/thetwo-way/2015/11/15/456094470/the-paris-attacks-what-we-know-right-now (Accessed: 6 April 2016). 11. Peralta, E. (2015a) Paris attacks live updates: French authorities identify key players. Available at: http://www.npr.org/sections/thetwo-way/2015/11/16/456181539/paris-attacks-live-updates-french-authorities- identify-mastermind (Accessed: 7 April 2016). 12.Khan, D. (no date) Is the NYPD really against Muslims? Available at: http://www.asmasociety.org/about/dk_huffpost.pdf (Accessed: 6 April 2016). 13.123, V. (2015)WATCH: What this Muslim police chief just did goes against EVERYTHING that is America! - Allen B. West. Available at: https://www.allenbwest.com/allen/watch-what-this- muslim-police- chief-just-did-goes-against-everything-that-is-america (Accessed: 8 April 2016). 14. Syrmopoulos, J. (2015)School nurse refuses to treat child as punishment for sitting down during pledge of allegiance. Available at: http://thefreethoughtproject.com/school-nurse-refuses-treat-child-stayed-seated-pledge- allegiance/ (Accessed: 8 April 2016). 15. Post, T.J. (2016)Hijab for female police officers: Is it really needed?Available at: http://www.thejakartapost.com/news/2014/08/01/hijab-female-police-officers-is-it-really-needed.html (Accessed: 5 April 2016). 16. Jeffreys, B. (2016) Can schools ban the veil? Available at: http://www.bbc.com/news/education-35413363 (Accessed: 6 April 2016). 17. HOUSE OF LORDS (no date) Available at: http://www.publications.parliament.uk/pa/ld200506/ldjudgmt/jd060322/begum.pdf (Accessed: 4 April 2016) 18. Kate, E. (2014) 4 Lies About School Dress Codes That Cover Up Their Oppressive Effects. Available at: http://everydayfeminism.com/2014/12/school-dress-code-myths/ (Accessed: 5 April 2016). 19.Ogbuji, C.N., Anyanwu, A.V. and Onah, J.O. (2011) ‘An empirical study of the impact of Branding on consumer choice for regulated bottled water in southeast, Nigeria’, International Journal of Business and Management, 6(6), p. 150. 20. Ogbuji, C.N., Anyanwu, A.V. and Onah, J.O. (2011) ‘An empirical study of the impact of Branding on consumer choice for regulated bottled water in southeast, Nigeria’, International Journal of Business and Management, 6(6), p. 150. 21. Reporter, D.M. (2011) Mother knows best: Why we stick to the same brands our mums used to buy. Available at: http://www.dailymail.co.uk/femail/article-1385576/Mother-knows-best-Why-stick-brands-mums-used-buy.html (Accessed: 8 April 2016). 22 .Tried and true or adventurous: Do consumers stick to their favorite alcohol brands? (2015) Available at: http://www.nielsen.com/us/en/insights/news/2015/tried-and-true-or-adventurous-most-consumers-stick-to-their- favorite-alcohol-brands.html (Accessed: 7 April 2016). 23. Gregoire, Y. (2016) The impact of aging on consumer responses: What do we know? By Yany Gregoire. Available at: http://www.acrwebsite.org/volumes/8729/volumes/v30/NA-30 (Accessed: 8 April 2016). 24. Walton, C. (2014) Will racism end when the old guys die off? Doubt it. Available at: http://www.cnn.com/2014/05/01/opinion/walton-millennials-racism-sterling-bundy/ (Accessed: 6 April 2016). 25. Harker, J. (2015) Why are people racist? You asked Google – here’s the answer. Available at: http://www.theguardian.com/commentisfree/2015/apr/30/why-people-racist-you-asked-google (Accessed: 5 April 2016). 26. Puar, J.K. (2007)Terrorist assemblages: Homonationalism in queer times (next wave: New directions in Womens studies). Durham: Duke University Press. 27. Guo, J. (2015) Hating Muslims plays right into the Islamic state’s hands. Available at: https://www.washingtonpost.com/news/wonk/wp/2015/11/17/isis-wants-you-to-hate-muslims/ (Accessed: 5 April 2016). 28. 9/11 anniversary sparks hate crimes against Muslims (2011) Available at: https://www.splcenter.org/fighting- hate/intelligence-report/2011/911-anniversary-sparks-hate-crimes-against-muslims (Accessed: 5 April 2016).

29. TheHuffingtonPost (2012) History of hate: Crimes against Sikhs since 9/11. Available at: http://www.huffingtonpost.com/2012/08/07/history-of-hate-crimes-against-sikhs-since-911_n_1751841.html (Accessed: 7 April 2016). 30. Sim, D. (2015)Vaisakhi 2015: Sikh devotees celebrate major festival in India and Pakistan [Photos]. Available at: http://www.ibtimes.co.uk/vaisakhi-2015-sikh-devotees-celebrate-major-festival-india-pakistan-photos-1496358 (Accessed: 7 April 2016). 31. Garg, B. (2015)A Sikh man’s Photoshopped image as A Paris attacker is going viral over the social media. Available at: http://www.talepicker.com/a-sikh-mans-photoshopped-image-as-a-paris-attacker-is-going-viral-over- the-social-media/ (Accessed: 7 April 2016). 32. Green, E. (2015) The trouble with wearing turbans in America. Available at: http://www.theatlantic.com/politics/archive/2015/01/the-trouble-with-wearing-turbans-in-america/384832/ (Accessed: 4 April 2016). 33. Network, A.J.M. (no date) Satire as wearing hijab is labelled ‘passive terrorism’. Available at: http://www.aljazeera.com/news/2016/02/satire-wearing-hijab-labelled-passive-terrorism-160224145610993.html (Accessed: 10 April 2016). 34. Why Hijab? (no date) Available at: http://www.al-islam.org/hijab-muslim-womens-dress-islamic-or-cultural- sayyid- muhammad-rizvi/why-hijab (Accessed: 10 April 2016). 35. BBC (2009) Religions - Islam: Hijab. Available at: http://www.bbc.co.uk/religion/religions/islam/beliefs/hijab_1.shtml (Accessed: 11 April 2016). 36. Haleem, M.A.A. and M A S Abdel Haleem (2008) The Qur’an: A new translation. Oxford: Oxford University Press. 37. Nadeau, B.L. (2014) Why does the Hijab get such A bad rap?Available at: http://www.thedailybeast.com/witw/articles/2014/04/05/how-hip-is-your-hijab.html (Accessed: 10 April 2016). 38. Marshall, L. (2015) Want to help ISIS? Hate a Muslim. Available at: http://www.huffingtonpost.com/leslie- marshall/want-to-help-isis-hate-a-_b_8584142.html (Accessed: 13 April 2016). 39. Tucker, P. (2015) Why join ISIS? How fighters respond when you ask them. Available at: http://www.theatlantic.com/international/archive/2015/12/why-people-join-isis/419685/ (Accessed: 13 April 2016). 40. BBC (2014) How extreme isolation warps the mind. Available at: http://www.bbc.com/future/story/20140514- how-extreme-isolation-warps-minds (Accessed: 11 April 2016).

41. Wood, G. (2016) What ISIS really wants. Available at: http://www.theatlantic.com/magazine/archive/2015/03/what-isis-really-wants/384980/ (Accessed: 11 April 2016). 42. Marglin, J. (2015) Why we cannot Conflate ISIS and Islam. Available at: http://www.huffingtonpost.com/jessica-marglin/isis-vs-islam_b_8613826.html (Accessed: 13 April 2016). 43. Kumar, D. (2012) Islamophobia: The cultural logic of empire. , IL: Consortium Book Sales & Dist. 44. Gumbel, A. (2015) Oklahoma City bombing: 20 years later, key questions remain unanswered. Available at: http://www.theguardian.com/us-news/2015/apr/13/oklahoma-city-bombing-20-years-later-key-questions-remain- unanswered (Accessed: 10 April 2016). 45. Singh, S.J. and simran-jeet-singh (2013) Flying while Sikh: Why racial profiling matters. Available at: http://www.thedailybeast.com/articles/2013/11/27/flying-while-sikh-why-racial-profiling-matters.html (Accessed: 13 April 2016). 46. Race, power and policy: Dismantling structural racism prepared for national people’s action by the grassroots policy project (no date) Available at: http://www.racialequitytools.org/resourcefiles/race_power_policy_workbook.pdf (Accessed: 14 April 2016). 47. Emba, C. (2016) What is white privilege? Available at: https://www.washingtonpost.com/blogs/post- partisan/wp/2016/01/16/white-privilege-explained/ (Accessed: 10 April 2016). 48.Dunn, C., Abrams, A. and Silva, C. (2015) Shopping while black: America’s retailers know they have A racial profiling problem. Now what? Available at: http://www.ibtimes.com/shopping-while-black-americas-retailers- know-they-have-racial-profiling-problem-now-2222778 (Accessed: 12 April 2016). 49.Boroff, D. (2015) Muslims booted from mall following ‘very strange’ behavior. Available at: http://www.nydailynews.com/news/national/muslims-taunted-facebook-tossed-mall-article-1.2473808 (Accessed: 12 April 2016). 50. Joshi, A. (2016) The big problem with ‘see something, say something’. Available at: http://www.huffingtonpost.com/anujoshi/the-dangers-of-see-something-say-something_b_9060958.html (Accessed: 15 April 2016). 51.ACLU (2016b) Surveillance by other agencies. Available at: https://www.aclu.org/issues/national- security/privacy-and-surveillance/surveillance-other-agencies (Accessed: 10 April 2016). 52. Graham, D.A. (2015) The TSA Doesn’t Work—and never has. Available at: http://www.theatlantic.com/politics/archive/2015/06/the-tsa-doesnt-work-and-maybe-it-doesnt- matter/394673/ (Accessed: 10 April 2016). 53. Goldberg, J. (2014) The things he carried. Available at: http://www.theatlantic.com/magazine/archive/2008/11/the- things-he-carried/307057/ (Accessed: 13 April 2016). 54. Sugiyama, S. (2016) Report of TSA behavior shows racist tendencies. Available at: http://dailyorange.com/2012/08/report-of-tsa-behavior-shows-racist-tendencies/ (Accessed: 11 April 2016). 55. Boston-Logan international airport (no date) Available at: https://www.massport.com/media/11189/01.11Avstats.pdf (Accessed: April 2016). 56. Gorman, R. (2015) 20 years after the Oklahoma City bombing, Timothy McVeigh remains the only terrorist executed by US. Available at: http://www.businessinsider.com/20-years-after-the-oklahoma-city-bombing-timothy- mcveigh-remains-the-only-terrorist-executed-by-us-2015-4 (Accessed: April 2016). 57.BBC (2001) Inside McVeigh’s mind. Available at: http://news.bbc.co.uk/2/hi/americas/1382540.stm (Accessed: May 2016). 58. CBSN (2000) What really happened at Waco. Available at: http://www.cbsnews.com/news/what-really- happened-at-waco/ (Accessed: May 2016). 59. Bennett, B. (2015) White terrorism is as old as America. Available at: http://www.nytimes.com/2015/06/19/magazine/white-terrorism-is-as-old-as-america.html (Accessed: May 2016). 60. Dawoody, A. (2010) Xenophobia, the other face of racism. Available at: http://patimes.org/xenophobia- the- other-face-of-racism/ (Accessed: May 2016). 61. Sputnik (2015) Iran celebrates 36th anniversary of Islamic revolution victory. Available at: http://sputniknews.com/middleeast/20150201/1017623158.html (Accessed: May 2016). 62. KPCC, 3 and Radio, S.C.P. (2015) Fear has some Muslim women deciding whether to wear hijab. Available at: http://www.scpr.org/news/2015/12/22/56360/climate-of-fear-has-some-muslim-women- making-diffi/ (Accessed: May 2016). 63. Vyver, J. (2014) Explained: Why Muslim women wear a burka, niqab or hijab. Available at: http://www.abc.net.au/news/2014-09-23/why-do-muslim-women-wear-a-burka-niqab-or-hijab/5761510 (Accessed: May 2016). 64. Power, C. (2015) Why there’s tension between France and its Muslim population. Available at: http://time.com/3659241/paris-terror-attack-muslim-islam/ (Accessed: May 2016). 65. Samuel, H. (2013) France unveils controversial ’secularism charter’. Available at: http://www.telegraph.co.uk/news/worldnews/europe/france/10296500/France-unveils-controversial-secularism- charter.html (Accessed: May 2016). 66. Chrisafis, A. (2016) France to overhaul secularism teaching to help stop radicalisation. Available at: http://www.theguardian.com/world/2016/jan/21/france-overhaul-secularism-teaching-anti-radicalisation- paris- attacks (Accessed: May 2016). 67. Winkler, E. (2016) Is it time for France to abandon Laïcité? Available at: https://newrepublic.com/article/127179/time-france-abandon-laicite (Accessed: May 2016). 68. Merriam-Webster (2015) Definition of RADICAL. Available at: http://www.merriam- webster.com/dictionary/radical (Accessed: May 2016). 69. Merriam-Webster (2015a) Definition of EXTREMIST. Available at: http://www.merriam- webster.com/dictionary/extremist (Accessed: May 2016). 70. Judicial Learning Center (2015) Law and the rule of law. Available at: http://judiciallearningcenter.org/law- and-the-rule-of-law/ (Accessed: May 2016). 71. Network, A.J.M. (2016) Defending Pakistani women against honour killings. Available at: http://www.aljazeera.com/indepth/opinion/2016/03/defending-pakistani-women-honour-killings- 160307075135769.html (Accessed: May 2016). 72. Rothkopf, D., Jacinto, L., De Luce, D., Hudson, J., Twining, D., Holmes, J., Knights, M., Francis, D., O’Grady, S. and Zaretsky, R. (2016) How french secularism became fundamentalist. Available at: http://foreignpolicy.com/2016/04/07/the-battle-for-the-french-secular-soul-laicite-charlie-hebdo/ (Accessed: May 2016). 73. President2016–•, Harvard, F. of and Eck, D. (1997) What is pluralism?Available at: http://pluralism.org/what- is-pluralism/ (Accessed: May 2016). 74. Hazareesingh, S. (no date) Hardline secularism will not solve France’s problems. Available at: http://www.ft.com/intl/cms/s/912ac3ba-c519-11e5-808f- 8231cd71622e,Authorised=false.html? siteedition=intl&_i_location=http%3A%2F %2Fwww.ft.com%2Fcms%2Fs%2F0%2F912ac3ba-c519-11e5-808f- 8231cd71622e.html%3Fsiteedition %3Dintl&_i_referer=&classification=conditional_standard&iab=barrier- app#axzz49dvV1juR (Accessed: May 2016). 75. Chandler, A. (2015) Marine Le Pen is winning the war. Available at: http://www.theatlantic.com/international/archive/2015/12/marine-le-pen-front-national-france/420348/ (Accessed: May 2016).

76. Chak, A. (2015) Trump v Le Pen: In their own words. Available at: http://www.bbc.com/news/magazine- 35075439 (Accessed: May 2016). 77. Sanchez, R. (2016) Bashar al-assad: I want to be remembered as the man who saved Syria. Available at: http://www.telegraph.co.uk/news/worldnews/middleeast/syria/12167068/Bashar-al-Assad-I- want-to-be- remembered-as-the-man-who-saved-Syria.html (Accessed: May 2016). 78. America, A.J. (2015) At UN panel, speakers call for end to Syria barrel bombs. Available at: http://america.aljazeera.com/articles/2015/9/28/at-un-panel-speakers-call-for-end-to-syria-barrel-bombs.html (Accessed: May 2016). 79. Yuhas, A. (2016) Jean-Marie Le Pen endorses trump days after ex-kKK leader urges support. Available at: http://www.theguardian.com/us-news/2016/feb/27/jean-marie-le-pen- endorses-donald-trump (Accessed: May 2016). 80. Kranish, M. and O’Harrow, R. (2016) Inside the government’s racial bias case against Donald Trump’s company, and how he fought it. Available at: https://www.washingtonpost.com/politics/inside-the- governments-racial-bias-case-against-donald-trumps-company-and-how-he-fought-it/2016/01/23/fb90163e- bfbe-11e5-bcda- 62a36b394160_story.html (Accessed: May 2016). 81. Chrisafis, A. (2016b) French minister Christiane Taubira resigns after fallout over terror policy. Available at: http://www.theguardian.com/world/2016/jan/27/french-justice-minister- christiane-taubira-resigns (Accessed: May 2016).